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French Enforcement Actions Under Sapin II

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The Agence Française Anti-Corruption (AFA) has recently taken action against two companies that violated the French Anti-Corruption Law, Sapin II. The AFA published two new Conventions Judiciaires d’Interêt Public (CJIPs), similar to American Deferred Prosecution Agreements (DPA), regarding corrupt payments.

As the first of their kind, these actions provide some insight into how CJIPs function, how penalties are assessed, the factors considered in determining penalties and how a monitorship “à la Française” may be structured for those companies caught making corrupt payments.

FCPA Blog

March 13, 2018

Meet the Authors

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About the Authors

Xavier Oustalniol

Xavier Oustalniol is a Partner with StoneTurn in San Francisco. He focuses on complex forensic accounting issues, fraud investigations and prevention, and anti-corruption matters, and provides consulting services regarding damages […]